Appeal Court Faults Federal High Court Judge Over PDP Leadership Ruling

The leadership crisis rocking the Peoples Democratic Party (PDP) took a fresh legal turn as the Court of Appeal, Abuja Division, faulted a judgment delivered by Justice Uche Agomoh of the Federal High Court, Ibadan Division, for granting reliefs that were not sought by any of the parties in the dispute.

In a recent judgment delivered by a three-member panel led by Justice Uchechukwu Onyemenam, the appellate court held that the trial judge went beyond the issues placed before her by the litigants when she recognized the Abdurahman Mohammed and Samuel Anyanwu-led caretaker committee as the legitimate leadership structure of the PDP.

The ruling is the latest development in the protracted legal battle over the control of the opposition party and carries significant implications for the legitimacy of actions taken by rival PDP factions in recent months.

Justice Agomoh had, on January 30, ruled in favour of the faction led by Abdurahman Mohammed and Samuel Anyanwu, declaring it the authentic caretaker committee of the PDP. However, legal observers immediately questioned the decision on the grounds that none of the parties before the court had specifically sought a declaration recognizing the committee as the lawful leadership of the party.

The Court of Appeal agreed with that position, stressing that courts are bound by the reliefs sought by litigants and cannot grant remedies that were neither pleaded nor requested.

“In the instant case, there is clearly a live issue where the trial court went outside the reliefs sought to recognize and uphold a factional caretaker committee,” Justice Onyemenam stated in the lead judgment.

The appellate court’s criticism centered on a well-established legal principle that a court cannot award a party reliefs beyond those sought in its pleadings, a doctrine commonly referred to in legal circles as ultra petita. Although the Court of Appeal stopped short of expressly describing the lower court’s action with the Latin phrase, its judgment effectively found that Justice Agomoh exceeded her judicial mandate.

The court further noted that the entire controversy surrounding the leadership structures purportedly created by the PDP’s Ibadan Convention had already been settled by superior courts.

According to the judgment, the Supreme Court had earlier nullified the Ibadan Convention held on November 15 and 16, 2025, thereby stripping any committees, organs, or leadership structures that emerged from that convention of legal validity.

Justice Onyemenam emphasized that once the convention had been declared null and void by the apex court, any structure built upon it automatically lost its legal foundation.

“Once the Convention itself has been pronounced null, void and of no effect by the Supreme Court, any superstructure erected upon it is necessarily without legal foundation,” the court held.

The appellate court consequently ruled that the legal basis upon which the Anyanwu-led caretaker committee was recognized had effectively been erased by the Supreme Court’s decision, leaving no subsisting issue requiring adjudication.

In a particularly strong passage of the judgment, the court stated that the portions of the Federal High Court ruling that exceeded the reliefs sought were liable to be invalidated.

“This Court would be driven to the conclusion that the offending portions of the judgment, and indeed the judgment as a whole insofar as the excess permeates the decision, are a nullity and liable to be set aside ex debito justitiae,” the judgment read.

The Court of Appeal also declined to order a retrial of the leadership dispute, reasoning that doing so would amount to reopening issues that had already been conclusively determined by the Supreme Court.

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“A direction to the trial court to retry an issue that has been settled at the apex level would, in effect, invite it either to repeat what has already been decided or to purport to sit in judgment over the Supreme Court, both of which the law forbids,” Justice Onyemenam stated.

The judgment was unanimously endorsed by the other members of the panel, Justice Mohammed Mustapha and Justice Okon Efreti Abang.

Delivering the court’s final position, Justice Onyemenam held that the combined effect of the Court of Appeal’s earlier decision in Appeal No. CA/ABJ/1695/2025 and the Supreme Court’s judgment in Appeal No. SC/CV/164/2026 had extinguished the dispute.

“On the merits, I hold that, by reason of the binding decisions of this Court in Appeal No. CA/ABJ/1695/2025 and of the Supreme Court in Appeal No. SC/CV/164/2026, which nullified the Ibadan Convention of 15th–16th November 2025 and settled the core issues underlying this appeal, there is no longer any live controversy between the parties,” the court ruled.

Legal analysts say the judgment effectively neutralizes the January 30 ruling of the Federal High Court and raises fresh questions about administrative actions taken on the strength of that judgment.

The decision is particularly significant because the Independent National Electoral Commission (INEC) had reportedly relied on the Federal High Court judgment in recognizing and retaining the faction’s details on its official portal.

With the appellate court now holding that the foundation of the ruling has been overtaken and rendered legally unsustainable by the Supreme Court’s decision, attention is expected to shift to the practical implications for the PDP’s leadership structure and any actions previously taken based on the now-discredited judgment.

The latest ruling is expected to deepen ongoing debates within the PDP over leadership legitimacy while reaffirming the principle that courts must confine themselves strictly to the reliefs sought by parties before them.

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